Theoretical Analysis of Turkey-EU relations after the Lisbon Treaty: Alignment through “Europeanization” or “Differentiated Integration”?

Full text

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Yıldız, A. (December, 2013). “Theoretical Analysis of Turkey-EU relations after the Lisbon Treaty:
Alignment through ‘Europeanization’ or ‘Differentiated Integration’?”. in Hürsoy, S. “Turkey’s Quest for
the EU: Membership Towards 2023”. Ege University Publications, Izmir
Theoretical Analysis of Turkey-EU relations after the Lisbon Treaty: Alignment through
“Europeanization” or “Differentiated Integration”?
Assist.Prof.Dr. Ayselin YILDIZ
Yasar University, Department of International Relations
ayselin.yildiz@yasar.edu.tr!
Introduction
Turkey-EU relations once again seem to be facing challenges in terms of a considerable drop in
their early momentum and the enthusiasm needed for the deep commitment of full-membership.
The golden age of Europeanization and reforms during the early years of the Justice and
Development Party (AKP) government seemed to have been forgotten in the current stalemate
triggered by domestic and external developments in the region. At the same time, the Lisbon
Treaty, which aims to further integrate the EU, has influenced the EU’s integration process by
bringing some new legal and institutional arrangements. It has also fostered increasing debate on
whether the EU should move towards a loosely structured “flexible integration model” rather
than a “deeply integrated model”. Although Turkey’s full membership aspirations face
difficulties given these dynamic changes and transformations concerning European integration,
Turkey’s membership objective remains irrevocable, and cannot be replaced by alternative
scenarios such as “privileged partnership”.
The aim of this paper is to analyze Turkey-EU relations after the Lisbon Treaty theoretically by
focusing on current developments and transformations in both the EU and Turkey. Through the
integration context, this paper will study Turkey-EU relations in terms of the extent to which the
EU’s rule and policy transfer towards Turkey has been successful within the accession
framework. Thus, beyond the “Europeanization” and “membership conditionality” debates that
have dominated the literature concerning the integration of candidate states into the EU, this
article will discuss Turkey’s accession story with its unique features by drawing on the insights
from two models, “external governance” and “differentiated integration” in order to explain the

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EU’s relations with third countries. This will provide a broader context for evaluating Turkey’s
integration into the EU. In doing so, the paper will scrutinize the conceptualization of
“integration” in the context of rule and policy transfer and adaptation as significant factors
pushing further cooperation. Regarding the current state of relations, where Turkey’s membership
conditionality has weakened, the paper will consider alternative scenarios to full membership, not
in terms of their feasibility as final aims, but as to whether they can provide useful models of
integration to revitalize and push accession negotiations by overcoming current deadlocks and
enable both sides to cooperate at different levels of integration. Finally, the paper will investigate
whether the methods and models of “external governance” and “differentiated integration” can
usefully contribute to further cooperation and integration between Turkey and the EU, thereby
allowing Turkey to gain full EU membership within the evolving map of a wider Europe.
Theoretical Analysis of “Rule and Policy Transfer” beyond the EU’s Borders
Although the European integration process has been intensively studied in theoretical terms,
theoretical studies of its relations with third countries and its external features and implications
have remained narrowly focused. Beyond studies of the “Europeanization” debate, which
investigates integration among the member states and integration of candidate states into the EU,
the existing literature on the theoretical analysis of the EU’s rule and policy transfer using other
models remains either descriptive or limited. The literature on the gradual extension of EU
policies to non-members, which significantly influences the integration process, tends to be
defined and associated with many interconnected notions, such as “external governance”
(Lavanex, 2004; Lavanex and Schimmelfennig 2009), “Europeanization” for candidate states
(Grabbe 2002; Schimmelfenning and Sedelmeier, 2005a; Sedelmeier, 2011), or “differentiated
integration” (Stubb, 1996, Kölliker 2006, Schneider 2009) for both candidate and non-member
neighbouring states.
The scope of European integration is extended either in the form of exporting EU norms and
rules to membership candidates within the context of EU enlargement or by exporting the EU’s
own regulatory model, institutions and rules of governance beyond the borders of formal
membership (Lavanex and Schimmelfenning, 2009). Rule and policy transfer, which pushes the
integration process through cooperation, is associated with political practices that have diverse
but inter-related conceptualizations. That is, it might refer to

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designing governance and policy extension beyond borders between at least two countries
sharing a specific asymmetrical relationship, not only in terms of power and socio-economic
disparities, but also in their capacities to politically respond to the same phenomenon
(Aubarell, Barrero, and Aragall, 2009: 12).
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This situation demonstrates the need for theorizing to move beyond the existing grand theories
and approaches of international relations or European integration. Among the alternatives,
“external governance” as a holistic approach, “Europeanization”, and various modes of
“differentiated integration” are some of the main overarching theoretical frameworks that seem to
provide a relevant context for scrutinizing the EU’s relations with third countries. While none of
these approaches is sufficient on its own to explain the field in its entire scope and context, by
complementing each other, they appear to offer a broader conceptual framework for a
comprehensive empirical context to best scrutinize the EU’s relations and rule transfer towards
third countries. It should be noted that the application of these theoretical approaches requires us
to take account of the EU’s unique structure, which complicates any attempt to explain the EU’s
engagement with third countries. The mechanisms of cooperation also differ depending on the
distinct context of grand policy frameworks, such as enlargement with a membership perspective
or the European Neighborhood Policy (ENP) without the membership incentive, as each has its
own specific aims, strategies and instruments.
Concerning the first conceptual framework, the analysis of the EU’s rule and policy transfer to
non-members is associated with the “external governance” approach (Lavanex and
Schimmelfenning, 2009:792). Although the notion of “governance” has traditionally been used to
address policy changes in the EU with regards to “internal governance”, the concept of “external
governance” explains some elements of the EU’s relations with other countries. In other words,
while the two forms of governance are closely related, internal governance focuses on the
creation of internal rules, whereas external governance focuses on the extension of these internal
rules and policies beyond formal membership to non-EU states (Schimmelfennig and
Sedelmeier, 2004: 661; Lavanex, 2004). Accordingly, the debate on external governance
addresses the EU acquis, rules and norms reaching beyond EU territory to affect third countries,
and how these third countries adopt them within their own legal systems (Rijpma and Cremona,
2007; 12).

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Modes of external governance constitute the first essential dependent factor for the study of
external governance. They provide the institutional forms and define the framework of the actors’
interactions and the mechanisms of rule expansion. Lavanex and Schimmelfennig (2009) define
three modes of external governance: hierarchical governance, network governance, and market
governance. These three modes are used for different countries and policy contexts by offering a
general framework to understand bilateral relations. While hierarchical governance provides a
broad context for the analysis of “conditionality” and top-down policy transfer, “network
governance” focuses on a bottom-up approach based on decentralized and sectorally specialized
governance institutions with functional expertise rather than political affiliation (Lavanex and
Schimmelfennig, 2009: 798). In this model, networks produce instruments based on mutual
agreement which involve negotiations and voluntary agreements, rather than producing binding
authoritative legislation. However, in this model, since the actors have equal rights and cannot
bind each other to a measure without the other’s consent to the relationship (Börzel, 2007), it
remains irrelevant to studying accession negotiations because they are based on the EU’s
overarching leverage. In fact, the network governance model might provide useful insights in
terms of its bottom-up approach and involvement of decentralized and sectorally specialized
governance institutions with functional expertise. These might better serve rule expansion,
specifically in the contested policies where cooperation and integration seem difficult. Lastly, the
mechanism of market governance helps to understand third countries’ adoption of standards and
compatibility with the EU, both in exchange for access to the EU’s internal market and as a
consequence of competitive pressure (Lavanex and Schimmelfennig, 2009). Although “external
governance” provides some relevant tools and mechanisms to explain rule expansion towards
non-member third countries through an institutionalist and structural perspective, it also has a
number of shortcomings in explaining EU policy transfer as it only refers to the assessment of the
legal transformation. When it comes to explanations beyond the question of legal and
institutional adaptation, such as norms and values with a full integration framework, external
governance remains limited in its scope and methodology.
The concept of “Europeanization” was previously largely confined in the literature to the impact
of European integration and governance on member states (Goetz and Meyer-Sahling 2008;
Ladrech 2009; Treib 2008). More recently, however, the main focus of such studies has
expanded, first from member states to candidates for membership (Schimmelfenning and

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Sedelmeier, 2005), and then to non-candidate states lying beyond EU borders as well
(Schimmelfennig, 2012). The recent literature has developed several overlapping definitions of
“Europeanization” (Radaelli 2000; Diez, Stetter, and Albert 2006; Bauer, Knill, and Pitschel
2007; Schimmelfennig 2009), although it generally refers to the domestic impact of, and
adaptation to, European governance in EU member states. In more concrete and broader terms,
Europeanization is defined as!
Processes of (a) construction, (b) diffusion, and (c) institutionalization of formal and informal
rules, procedures, policy paradigms, styles, ‘ways of doing things’, and shared beliefs and
norms, which are first defined and consolidated in the making of EU decisions and then
incorporated in the logic of domestic discourse, identities, political structures and public
policies (Radaelli, 2000:4)
The conceptualization of Europeanization differentiates between “traditional Europeanization”,
which is mainly limited to the EU member states, and “membership conditionality driven
Europeanization”, which affects candidate countries (Moga, 2010:6). In the enlargement context,
the EU exerts its influence and tries to push domestic change in candidate countries through the
principle of conditionality on the basis of the Treaty on European Union, Article 49: “Any
European state which respects the principles set out in Article 6 (1) may apply to become a
member of the Union”. These principles are defined as “liberty, democracy, respect for human
rights and fundamental freedoms and rule of law”. Thus, conditionality is a central concept of
Europeanization, where membership as the final goal is conditional on the adoption and
implementation of EU rules. It is used as one of the main foreign policy instruments of the
enlargement policy, where the EU holds the greater bargaining power to ensure the third
country’s compliance (Schimmelfening and Sedelmeier, 2005).
In the framework of satisfying the Copenhagen criteria for membership, during the accession
process, the EU largely relies on positive and negative conditionality while expecting candidate
countries adopt and implement the acquis communautaire (Börzel and Soyaltin, 2012). In other
words, policy transfer occurs in a predetermined framework, performed through regular
monitoring mechanisms regarding the adoption of EU rules (Schimmelfening and Sedelmeier,
2004: 674). The EU pro-actively promotes its model and rules of governance by making the
rewards for external actors from the EU conditional (Schimmelfennig, 2010:326). In positive
conditionality, the EU monitors the progress of candidate countries before offering them the

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chance to proceed with negotiations whereas, in negative conditionality, it delays implementing
the following stages in the accession process (Smith, 1998). Candidate countries do not have the
possibility of opt-outs from parts of the negotiation framework. The dominant basis of the EU’s
conditionality is the bargaining strategy of reinforcement by reward (Schimmelfennig,
Sedelmeier, 2004). The effectiveness of this conditionality depends on the size of the rewards, the
degree of credibility and the EU’s greater bargaining power (Schimmelfennig, 2010). However, if
the domestic adaptation costs are higher than the rewards then the rational choice of the non-EU
state might be to reject the conditionality (Schimmelfennig and Sedelmeier, 2005b).
In the most recent conceptual debate, studies on “differentiated integration” directly relate
questions about the legal conception of the EU and the extension of the validity of its rules
among members and to candidate countries. However, this conceptual framework also has its
limitations since the literature suffers from the lack of grand integration theories. Because
integration theories have traditionally focused on vertical integration, which tries to explain the
transfer of competencies from national to European level, differentiated integration was not a
prominent topic in the 1960s and 1970s (Holzinger and Schimmelfennig, 2012). The debate only
became an important feature of European integration in the 1990s because the EU’s imminent
Eastern enlargement would increase the heterogeneity of member states. This heterogeneity was
also caused by political “internal diversity” within the EU, which indicated a lack of national
consensus between member states about the EU and its integration project (Closa, 2010: 2). The
causal link between enlargement and differentiation is clear: “[the] increase in heterogeneity
among member states [is] triggered mainly by enlargement rounds but also by broadening the
functional scope of EU-level policy-making and the centralization or supranationalization of
decision-making” (Holzinger and Schimmelfennig, 2012: 299). Thus, although the focus in the
1990s was more on centralization and institutionalization concerning European integration,
differentiated integration has since become an issue as to whether it allows further integration in
various ways. In fact, it offers a space for exclusion and opt-outs to counter the lack of political
will for EU rule and policy expansion in some member states. Second, it counters the deadlock
stemming from increasing heterogeneity among both member states and transnational
externalities (Holzinger and Schimmelfennig, 2012). Finally, “differentiated integration” has
recently been discussed in terms of employing its various models to relations between the EU and
third countries as well as between EU member states. It is also called “external differentiation”,

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which refers to the decision to move from no integration to selective, policy-specific integration
of non-member states (Schimmelfenning, Leuffen and Rittberger, 2011).
Although the conceptual aspect of “differentiated integration” has been studied to some extent, an
explicit theory has not yet been provided and the concept lacks systematic empirical support
since the various models and paradigms of differentiated integration have led to a confusing
abundance of conceptualizations (Holzinger and Schimmelfennig, 2012).!In fact, each model is
distinct, although they share some common features. Differentiation has become an increasingly
relevant aspect of European integration in which the EU is studied as a system of differentiated
integration that incorporates the features of federal (type-1) as well as functional (type-2) multi-
level governance (Schimmelfenning, Leuffen and Rittberger, 2011) According to Alexander
Stubb’s (1996), widely accepted and used three-way classification differentiated integration can
be variously conceptualized as temporal differentiation, such as the “two- or multi-speed
Europe”, territorial differentiation, such as the “core Europe” or “Europe of concentric circles”,
and sectoral differentiation, such as “variable geometry”.
The “multi-speed Europe” model relates only to member states and aims to introduce a federal
Europe (Holzinger and Schimmelfennig, 2012) with all states participating in all EU policies
while integrating their domestic policies at different speeds and at different stage, depending on
their ability to implement them (Closa, 2010:2). In this model of supranational federalism idea,
some member states integrate more quickly in certain political fields to be followed later by other
members. However, political and legal unity within the EU remains the main goal for all
members (Brandt, 1975; Tindemans, 1976). The models of “core Europe” or “Europe of
concentric circles” refer to a federal political union in which certain core states define the center
of gravity around which the European policy integration will develop (Holzinger and
Schimmelfennig, 2012; Closa, 2010). Other member states form a second circle while those non-
member states willing to implement some EU policies constitute a third circle. The final model,
“variable geometry”, includes both member and non-member states. Closa (2010: 2) defines
variable geometry as a “descriptive model of the system in which, within a common integration
scheme, different groups of states participate in different policies”. In this model, those states that
are lagging behind have the right to participate in newly integrated areas, whether through
existing treaties or not, but they are excluded from participating in decision-making (Karakas,

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2013: 8). Thus, the discussion also concerns third countries in the wider European neighborhood
as it tries to analyze the implications of the deeper political, economic and societal integration in
Europe of certain countries for others located on Europe’s borders (Tassinari, 2007:1).
All these existing models of differentiated integration respond to the specific demands of
individual states by providing ad hoc solutions. Some of these formulas have been incorporated
into EU legislation, such as the UK’s opt-out from the European Social Charter, which was
adopted as a protocol to the Single European Act, while the British and Danish opt-out from the
third phase of Economic and Monetary Union can be situated within the model of variable
geometry (Closa, 2010). Beyond the monetary realm, the opt-outs of the UK, Ireland and
Denmark to the Schengen acquis are other cases which refer to models of differentiated
integration. Certain opt-outs were also retained in the Lisbon Treaty, such as the UK and
Poland’s opt-out from the Charter of Fundamental Rights, which was incorporated into the
Lisbon Treaty with a protocol. Contrary to arguments that such flexible formulas might weaken
EU integration by hindering deepening and creating “spill-back” effects, in reality they have
supported European integration, which might otherwise have stumbled or been blocked due to
clashes of national interests. In this context, the modes of differentiated integration resemble the
modes of “external governance” in terms of the sector-specific extension of the EU’s acquis.
The Impact of the Lisbon Treaty on European Integration
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The Lisbon Treaty (2009) marked a significant step in the history of European integration in
terms of improving the EU’s enhanced deepening strategy and institutional structure, with the
lessons learned from past enlargements leading the EU to revise its institutional structure and
decision-making procedures. Accordingly, the treaty shapes the EU’s future by redesigning the
institutional set-up and voting procedures with a focus on developing a supranational EU identity.
As Nas (2009) observes, the treaty might also be interpreted as a further step towards a federal
Europe.
Abbasov (2011) argues that Lisbon has affected the development of European integration in three
ways. First, it brought about changes in decision-making processes. Secondly, it introduced
common principles to strengthen integration among EU members. Finally, it attempted to
strengthen the grounds for integration in foreign policy. One particularly important change

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concerning decision-making was the further enhancement of qualified majority voting in the
Council, which offers room for “enhanced integration”. This has helped to eliminate the obstacles
and national barriers in decision making, where some states want to keep their sovereignty on
some controversial issues. It is considered as one of the most effective modifications enhancing
integration throughout Europe. Additionally, double majority voting has been introduced, which
requires the votes of 55% of states in favor representing 65% of the population, while a minimum
number of four states is needed to constitute a blocking minority to prevent a legislative proposal
being adopted. With the exception of taxation, foreign policy, defense and social security, and
enlargement, this will become effective from November 2014 (Eralp, 2009:3).
The Lisbon Treaty also strengthens integration by defining common principles and aims for the
EU’s external and internal affairs. The treaty lists common European values and principles of
democracy, the rule of law, the universality and indivisibility of human rights and fundamental
freedoms, respect for human dignity, and principles of equality and solidarity. These values and
principles represent the criteria that all accession countries are expected to meet. Another impact
of Lisbon on European integration was to stimulate the integration process at a high policy level
by establishing a senior representative and full-time new post of President of the European
Council. This aims to increase cooperation over EU foreign policy to allow stronger foreign
policy representation in the world affairs.
Thus, the Lisbon Treaty marks a significant step in terms aiming to strengthen the deepening
strategy of the EU while also leaving room for intergovernmental cooperation beyond treaty-
based relations. It has provided ways for flexible integration by offering some practical methods
of differentiated integration that help overcome the rigidity of institutional and formal settings of
the EU for some areas. As Closa (2010:1) notes, “the Treaty includes a number of modalities of
differentiated integration, which did already exist, such as enhanced cooperation or opt-outs, and
it adds some new forms such as opt-ins and permanent structured cooperation on defence”.
Since the way Turkey will eventually integrate into the EU is directly related to how the EU will
evolve, the Lisbon Treaty provides important insights into Turkey’s membership prospects.
Those that envisage the future of the EU moving towards a more British-style integration model
and intergovernmental direction, with relatively flexible boundaries allowing significant scope

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for national autonomy, favour Turkey’s membership more (Onis, 2008). That is, if the EU
follows a variable integration model, where cooperation on security, monetary policy or mobility
does not require strong cohesion, Turkey might be more welcome as a member since it will not
burden the EU as much as previously expected (Goksel, 2012: 3). However, the French project of
a deep integration model with fixed boundaries considers Turkey as an “important outsider rather
than a natural insider” and favours a special partnership model (Onis, 2008).
Turkey’s Integration into the EU through Europeanization
Turkey’s EU membership bid, based on long-standing expectations and commitments, is among
one of the most complex and disputed topics in European public debate. It related with the
questions about Europe’s spatial, strategic and conceptual limits (Tassinari, 2007). Turkey was
first declared as a candidate at the Helsinki Summit of 1999, with negotiations for full
membership opening in October 2005. Both decisions were taken using the EU’s unanimity
voting system, with Turkey being expected to harmonize its policies with the EU’s acquis
communitaire by adopting European values of respect of human dignity, freedom, democracy,
equality, rule of law, human rights and minorities. This framework provided the context for
Turkey’s “Europeanization” drive, referring to a process of interrelated economic and political
reforms in line with EU conditionality.
With the powerful incentive of membership, Turkey made a series of economic and political
reforms that strengthened democratizing transformations between 2002 and 2005 until accession
negotiations were formally opened. These early years of AKP government represent the golden
age of Turkey’s Europeanization with its commitment to implementing the Copenhagen criteria
in both the economic and political realms (Öniş, 2008:38). This led the European Council at its
December 2004 Summit in Brussels to decide to open negotiations without delay. This formal
Europeanization process, by promoting the continuation of the earlier successful reform period,
had had profound impacts on Turkey. Turkey has engaged in a fast-paced and extensive reform
of legislation and institutional restructuring in order to fulfil the Copenhagen political criteria.
The reforms have strengthened and contributed to the consolidation of democratic norms and
values and societal modernization in Turkey. Additionally, in the post-crisis era that follows the
2008-09 global financial crisis, the Turkish economy achieved one of its most successful growth

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phases. Significant examples of this successful transformation include improvements in civil-
society relations, respect for minority rights, a reduction in the military’s influence in Turkish
politics, improvements in respect for human rights, and the harmonization of Turkish institutions,
policies and legislation with the EU acquis.
However, subsequent developments in both Turkey and the EU have hindered negotiations. In
2006, the European Council decided to suspend accession negotiations on eight chapters of the
acquis due to Turkey’s refusal to open its ports to Greek Cypriot vessels before the Union ended
its isolation of Turkish Cyprus. This was followed by a certain loss of enthusiasm and
commitment by the government, which adjusted its foreign policy stance from focusing only on
Europe to “soft Euro-Asianism” in the post-2005 era (Öniş, 2008: 40). Turkish Prime Minister
Recep Tayyip Erdoğan mentioned leaving the EU track and the possibility of Turkey’s becoming
a member of the Shanghai Cooperation Organization (SCO), which aims to develop regional
cooperation mechanisms in defense and security in Eurasia. !EU concerns that Turkey has an
inherently non-European disposition have also been exacerbated in recent years by Turkey’s
rapprochement with Muslim countries in the Middle East, the Gulf region and Africa. In fact, the
prolonged negotiations and stagnation of the EU membership process were among one of the
significant reasons that pushed Turkey to seek alternative partners for its new economic and
political investment strategies (Hürsoy, 2013:3). Turkey’s ambitious and comprehensive
approach aiming to embrace enhanced economic, cultural and social ties, as well as political and
security relations with these countries are elaborated as signalling Turkey’s aspiration to become
a regional power. Turkey’s efforts to assert itself in this way has increased disagreements among
the EU member states about how to reach a consensus if Turkey became a member state (Göksel,
2012:2). Meanwhile, starting in 2009, the EU faced the Eurozone crisis, which had adverse
economic effects for the worst hit countries that led to social crises with major political impacts
for many Eurozone governments, especially Greece, Portugal, Italy and Spain. The severe
economic, social and political consequences of these crises led some to question whether
European integration was relevant for all the member states in terms of the EU’s one-size-fits all
approach. This led to a focus on the need to rethink the integration models for the future of the
EU.

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In fact, beyond the changing political and economic context at both sides, the unclear
membership prospect and the declining credibility of the EU have strongly induced the slowing
down of the accession negotiations. Schimmelfening argues that the “credibility of threats and
rewards is a core prerequisite of any effective bargaining process” (Schimmelfening and
Sedelmeier, 2005: 33). Therefore, the main determining factors in the success or failure of
Turkey’s accession through Europeanization are those developments that have caused a loss of
trust in EU conditionality and legitimacy and the increasing doubts of Turkish policy makers
about the prospects for the ultimate reward of membership.
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The credibility and sincerity of the EU’s commitment to Turkey was further weakened as by an
increase in the concerns that have always existed among some member states about the possible
implications of Turkish accession into the EU. Very recently, for example, German Chancellor
Angela Merkel stated that, “We [Germany] reject full membership for Turkey, because the
country does not meet the criteria for joining the EU. The country would overburden the
European Union because of its size and the structure of its economy” (Reuters, 2013). There have
been several other cases of such negative discourse regarding Turkey’s membership, such as the
speeches by former French President Nicolas Sarkozy against granting full membership to
Turkey, offering instead a “privileged partnership”, a “strategic partnership”, or a “Mediterranean
Union”, together with a renewed emphasis on worries about the “EU’s absorption capacity”
concerning Turkey’s membership prospects (BBC News 2010; EUobserver 2007; The New York
Times; 2008, Reuters, 2008). Stefan Füle, EU Commissioner for Enlargement, expressed his
fears concerning the possibility of a “train crash” over Turkey’s accession process due to the
Cyprus problem and voting over the so-called Armenian Genocide in the French Parliament.
Besides, the repeated emphasis on “cultural differences” in EU-Turkey relations has also
triggered mistrust in the EU and reinforced a decline in support for EU membership in Turkish
society.
Such mistrust is also clearly reflected by Turkish officials as well, who complain that the EU
does not treat Turkey fairly, in the same way as former and other current candidate countries, but
instead applies double standards. For example, Egemen Bağış, Minister of EU Affairs and Chief
Negotiator, wrote in a commentary for the Guardian newspaper that “[the] EU’s credibility has

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weakened in Turkey and public support for EU membership has declined, with less than half in
favour of joining. More alarming, 92% of Turks believe that the union has ‘double standards’
when it comes to Turkish accession” (Bağış, 2011). According to the Transatlantic Trends Survey
(2010) issued by the German Marshall Fund, the proportion of Turkish public opinion in favour
of EU membership dropped from 73% in 2004 to 38% in 2010. This trend has negatively reduced
motivation and progress in the necessary reforms and success of policy transfer, since the Turkish
government no longer feels any impetus itself, or from public pressure, to proceed with the
reforms and negotiations. As Turkey’s ambassador to the EU, Selim Kuneralp, told EUobserver
in an interview on 17 June 2011,
[t]he European Commission’s recommendations will be taken on board to the extent that they
reflect universal norms. Take the death penalty [which Turkey abolished in 2004]. Whether
or not you want to join the EU, it’s a good thing to abolish the death penalty. But in the
absence of any clear perspective of accession, there’s no reason why Turkey should align its
legislation toward narrow EU standards. To put it simply, the EU has lost its leverage on
Turkey (EUobserver, 2011).
Thus, due to a mix of external and domestic developments, we observe today a stalemate and a
deterioration in relations following the golden age of Europeanization and reform, particularly
during the early years of the AKP. As the credibility of the EU conditionality decreases, the
reward of membership has lost its power to effectively encourage Turkey’s further transformation
through Europeanization. Besides, it can be observed that the impact of Europeanization across a
range of issues and policy areas has changed in terms of its extent, pace and nature. For example,
as summarized by Öner (2012), Europeanization was successful in terms of strengthening civil
society organizations in Turkey through democratizing legal reforms and fostering social learning
by the internalization of European norms. A positive transformation has also been observed
concerning minority and women’s rights. However, both the Europeanization of Turkish social
policy reform and Turkish environmental policy have remained weak due to several EU-related
and domestic factors. Turkey’s migration and asylum policies constitute another contested area
where Turkish compliance with the EU’s acquis has been slow and weak. Turkey’s accession
negotiations with the EU have reached “virtual political and technical stalemate” (Morelli,
2013:7). The EU’s “Positive Agenda”, which was officially launched by the EU Commission in
2012 to revive the already damaged negotiations and support Turkey’s efforts to align with the

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EU acquis, has not helped at all to solve the essential problem of the formal stalemate.
Throughout 2011-13, no new chapters of the acquis were opened and very little progress was
achieved within the chapters already under negotiation. The European Commission expressed its
overall disappointment with Turkey’s progress on a number of issues in its 2012 regular report.
In return, Turkish government expressed its own disappointment, describing the report as
“biased” and “unbalanced”.
Alternative Integration Models for Turkey’s Accession
Although Turkey is confronted with many hurdles while negotiations continue at a slow pace
with longer delays, the single most crucial aspect of the negotiation process for Turkey still
remains the final goal, which for Turkey is accession to the EU as a full member state. However,
as stated in the Presidency Conclusions of the Brussels Summit of 2004, “These negotiations are
an open-ended process, the outcome of which cannot be guaranteed beforehand”. Moreover, the
EU has introduced the possibility of long transitional periods, derogations, specific arrangements
or permanent safeguards on full labor mobility, structural policies and agriculture following
Turkey’s accession to the EU as a full member (Council of the EU, 2004:7). These potential
impositions indicate that Turkey might be asked to accept a “second division status and a special
partner position even if it were to become a full member” (Öniş, 2008:41). This might be
interpreted as Turkey’s integration to the EU even after the membership, is argued through
different integration models. The permanent safeguard clauses offer institutional ties below the
level of full membership, suggesting that Turkey would not receive full membership rights even
if it successfully finished the accession negotiations, but would be offered “full membership
minus” instead (Karakas, 2013:5).
The article goes on to state what would follow if Turkey’s accession process did not end in
membership in order to demonstrate the EU’s consensus that Turkey should be integrated within
the EU in some way: “While taking account of all Copenhagen criteria, if the candidate State is
not in a position to assume in full all the obligations of membership it must be ensured that the
candidate state concerned is fully anchored in the European structures through the strongest
possible bond”. Thus, with or without full membership, the EU sees Turkey as a country that, for
the first time in its enlargement strategy, it must somehow integrate into Europe through various

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alternatives and models of integration (Karakas, 2008:25).
As Turkey’s efforts at Europeanization have faltered and negotiations have deteriorated,
conservative circles in particular in Germany, France and Austria have moved towards favouring
alternative options to full EU membership in the form of a “strongest possible bond”, such as the
so-called “privileged partnership” (Tassinari, 2007). This proposal entails a substantially deeper
integration of Turkey into the EU in some areas while excluding others, and without offering full
membership. It proposes to strengthen existing economic relations by overeating a
comprehensive free trade area. Beyond the economic field, the partnership model includes the
strong possible alignment of Turkey with the EU’s Common Foreign and Security Policy
(CFSP). It also favors strong cooperation, and close alignment in fields like internal security,
including data protection, the exchange of personal data and the convergence of visa policies and
practices (Tassinari, 2007). However, Turkey would not have the right to participate in decision-
making.
For Turkey, the sole, irrevocable goal of the accession negotiations remains full membership. By
introducing permanent safeguard clauses, the EU’s current negotiating framework only offers
Turkey a kind of differentiated integration model. That is, it still aims to affect Turkey’s
integration without granting absolute membership rights even if accession negotiations are
completed. As long as the EU does not offer Turkey a clear prospect of membership that includes
full membership rights without permanent safeguard clauses, it seems likely that the process of
integrating Turkey with the EU will continue slowly and with many hindrances. Given this
likelihood, various modes of differentiated integration may provide insights and flexible ways to
overcome future obstacles during negotiations over contested policy areas since deeper and fuller
integration may get delayed depending upon the safeguard clauses foreseen in the negotiations
framework as well. On the other hand, the problems that have been experienced during
negotiations especially on contested policy areas prevent progress that might occur in other areas.
Otherwise this might accelerate Turkey’s integration at various levels. Ultimately, however, it is
in the nature of accession negotiations that the EU holds hierarchical power within its own
enlargement policy so Turkey is expected to harmonize its policies and adopt the acquis in full.
Nevertheless, membership conditionality has not worked effectively; rather, it has limited or

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hindered progress in Turkey’s Europeanization in many policy areas. Thus, looking beyond the
Europeanization and conditionality context, the network governance and differentiated
integration models may help to overcome the existing difficulties through the different methods
and flexible ways they offer, especially in cases where the negotiation process stranded. Although
both models remain limited in contextual and methodological terms since they mainly refer to
integration between equal partners, network governance nevertheless provides insights for issue-
specific integration models where a bottom-up cooperation approach is mainly dominated by
decentralized and sectorally specialized governance institutions. Similarly, the differentiated
integration model has been proved to foster integration by offering flexibility against the threat of
disintegration. Although the negotiation process cannot be fixed in such modelling of flexibility
within the current enlargement context, it might help to limit the risk of negotiations slowing or
being suspended as an alternative to strict hierarchical models where conditionality is weak.
Another version of this model, gradual integration/membership, proposed by Karakas (2013),
aims at the successive thematic and structural integration of Turkey through several steps that are
conditional to each other’s success. None of these alternative models are meant to lead to
“differentiated membership” or “privileged partnership” because the final aim for Turkey is full
membership but they might be used to provide a broader and more effective context to indicate
alternative ways to cooperate to overcome current slow-down in the Europeanization and
integration of Turkey within the EU.
Concluding Remarks
The success of Turkey’s integration with the EU can be evaluated in terms of whether EU rule
and policy transfer and adoption occurs at the expected level within the framework of the
accession negotiations. In an attempt to analyse the transformation process and domestic change
in Turkey as a candidate, Europeanization is taken as the main overarching contextual approach.
However, it is observed that EU’s mechanisms of membership conditionality have been weak and
there has been a loss of enthusiasm in Turkey’s pursuit of Europeanization. Models of “external
governance”, applicable to non-member third countries, and “differentiated integration”,
applicable to both member states and third countries, provide a broader framework to analyze
how cooperation and integration occur through policy expansion although the literature on these
theoretical models trying to explain the EU’s rule and policy expansion remain limited in terms

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of their applicability to candidate countries. In fact, both concepts suggest alternative ways and
methods of overcoming obstacles in the cooperation framework that mainly caused by specific
conflicting interests.
The debate concerning the EU’s own integration model, whether it should lead to a flexible or
deeply integrated system, is closely linked to the study of the EU’s relations with third countries
in terms of its rule and policy expansion. The Lisbon Treaty can be evaluated as an important
step towards a federal Europe, backed by flexible integration models in different policy areas by
different member states. Internal developments, and the way the EU conceptualizes its own
integration model, have played an important role in shaping the externalization of its rules, norms
and policies towards both candidate and non-member countries.
!
Concerning the Turkish case, the accession framework aims to link Turkey more closely linked to
EU while not automatically making it fully part of the EU, even after the successful completion
of negotiations. That is, the EU may still expect Turkey to continue its integration efforts after
completing negotiations to become a full EU member, which suggests a different enlargement
context. On these grounds, to tackle the existing obstacles and difficulties in certain policy areas
that are hindering cooperation and harmonization in other areas, different models of differential
integration may offer useful insights and methods to facilitate Turkey’s gradual integration.
Although differentiated integration is mostly debated in terms of whether it places the EU toward
dissolution or deeper integration, it has, through the flexibility it offers, effectively contributed to
preventing stagnation in the integration process regarding specific EU policies. In the same
manner, since the current negotiation framework foresees that the process might continue even
after successful completion of the chapters, which will hinder the achievement of full
membership status, Turkey may do better to proceed using the methods and ways of “network
governance” and “differentiated integration” in order not to get stuck in blocked negotiations.
Given the weakened conditionality, slowed Europeanization and decreased credibility of the EU
among Turkish politicians and society, these alternative cooperation mechanisms, which have
been used for third countries and member states, can better contribute to foster the integration
that might lead to successful completion of the acquis chapters more quickly than the use of
hierarchical models, which require strong and credible conditionality. Regarding the changing
dynamics, transformations and domestic developments taking place on both sides, the

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applicability of these methods to some specific policy areas might be tested through further
empirical studies in order to contribute to the sustainability and success of integration dynamism
in Turkey-EU relations.
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